Sharpening the Practice - a review of the management and processes for early learning complaints and incidents

Summary of report


  • An important role of the Ministry of Education is to ensure that all licensed early learning services and certificated playgroups (early learning services) are meeting regulatory requirements to provide quality education and care.
  • We make sure that parents, whānau and kaiako are able to voice their concerns about an early learning service, and that they are heard. That includes concerns they have about how we respond.
  • Our management of complaints and incidents is one of a number of ways we identify whether an early learning service is continuing to meet regulated standards. How we manage and respond to complaints is important to give parents and whānau confidence that their tamariki are learning in safe, quality and well-run early learning services.
  • In 2018, the Ministry of Education commissioned an independent review of our early learning complaints and incidents management processes. This was led by an external reviewer, who considered the Ministry’s effectiveness at managing and responding to complaints and incidents in early learning.
  • A range of stakeholders participated in the review process, including representatives from sector peak bodies, relevant agency managers and key personnel / members of the public who have an interest in the Ministry’s complaints and incidents process.
  • The resulting report, ‘Sharpening the Practice – a review of the Ministry of Education’s management processes for early learning complaints and incidents (the report) was provided to the Ministry in early 2019.

Key findings

  • Overall, the report identifies that Ministry staff use day-to-day processes well when managing and responding to complaints and incidents in early learning. The review found that Ministry staff take effective actions when responding to complaints and uphold our commitment to respond to all complaints seriously.
  • The report makes ten recommendations to further strengthen the Ministry’s practice when managing and responding to complaints and incidents in early learning. Each of the report’s recommendations are outlined in the table below, along with our response. 

Recommendations and Ministry responses

The following table outlines recommendations and Ministry response from Sharpening the Practice - a review of the Ministry of Education’s management and processes for early learning complaints and incidents 

 Theme Recommendation Response
Intervening on a child’s behalf
  • Ensure all staff involved in the complaints process – including Managers – have training to identify risk, as set out in the risk matrix.  Provide exemplars so that staff understand and are confident about the boundaries between risk categories.
All complaints and incidents received by the Ministry are assessed to determine the level of risk and identify appropriate next steps. Timely escalation of serious complaints supports the Ministry to respond effectively.  The report’s recommendation to strengthen staff training in this area has been incorporated into our broader programme of work.
  • Consider updating the Education Regulations so they are fit for purpose in the current early learning environment.
A Ministry-wide review of regulations is currently underway, which will address the report’s recommendation to clarify aspects of the Education (Early Childhood Services) Regulations 2008.
  • Look into how the use of unannounced visits might be integrated as part of wider monitoring of early learning services that are persistent poor performers and where multiple complaints have been made.
While the Ministry currently can, and does, conduct unannounced visits to support our monitoring and enforcement roles, the draft Strategic Plan for Early Learning has recommended increasing our monitoring role further to raise quality provision. If progressed, this recommendation will also consider the use of unannounced visits as part of a broader monitoring strategy.
National and regional coherence
  • In the short term, progress the suggestions identified to improve the current complaints management system and in the medium to longer term investigate whether the current system is the most appropriate way to capture complaint information and progress it in a timely manner. 
We are continuing to progress work already underway to improve our systems and share best practice, which gives effect to these recommendations.  
National and regional coherence
  • In the interests of greater consistency, explore ways to share regional expertise and innovation. Consider regional access to Early Learning Information systems as part of this approach.
We are considering the implications of providing regional access to Early Learning Information system data. This will require careful management and assurance processes to ensure there are clear rules in place to guide the use and application of this information, noting privacy considerations.
Continuous improvement focus
  • One training package should be developed at national level with input from strong regional expertise.
  • Rationalise policy and guidance documentation on the complaints process.
  • Find regular opportunities for relevant staff with early learning experience to meet regularly. Build in a moderation component to their roles.
  • Improve the quality of monthly and annual complaints and incidents reports by asking broader evaluative questions of the data. 
Recommendations focussed on continuous improvement are being actioned through existing programmes of work focused on refining internal guidance and further developing our reporting on complaints and incidents management in early learning.
Communication and collaboration for credibility
  • Urgently communicate the Ministry’s policy and processes through the most appropriate vehicles that will reach not only the peak bodies but sector members. Include information about on-site visits.
A web page is available that outlines the Ministry’s processes when responding to complaints about early learning services. Services can contact the local Ministry of Education office for further information about making a complaint or how the Ministry responds to a complaint.

This content is also available as a downloadable PDF document:

Summary of sharpening the practice [PDF, 308 KB]

Sharpening the Practice - ECE Complaints full report

Sharpening the Practice - ECE Complaints full report [PDF, 4.1 MB]

Last reviewed: Has this been useful? Give us your feedback